Introduction
As the premier financial appraisers and evaluators of the equestrian sport in the United States and North America and because we operate in the public spotlight, we are expected to conduct our affairs in a manner consistent with the great trust that has been placed in us. This requires our behavior to conform to the highest ethical principles.
For these reasons, North American Equine Services, LLC, (NAES), requires its staff to conduct business with integrity, to maintain a standard of ethical conduct consistent with the regulations of all jurisdictions in which NAES conducts business, and to be guided by the knowledge that we are guardians of equestrian valuation and must maintain the values, spirit, and ideals of the sport and its part in the international movement.
Furthermore, because the appearance of impropriety can be just as damaging as actual impropriety, conduct which appears to be improper is also unacceptable. (See definitions below.) Accordingly, we are required to comply with the following NAES Code of Ethics when representing or participating in NAES activities or procedures:
1. Conduct all dealings with honesty and fairness.
2. Respect the rights of all employees to fair treatment and equal opportunity,
free from discrimination or harassment of any type.
3. Know, understand and comply with the laws, regulations,
and codes of conduct governing the conduct of NAES business – both domestic and foreign.
4. Ensure that all transactions are handled honestly and recorded accurately and openly where possible.
5. Protect information which belongs to NAES its clients and suppliers.
6. Avoid conflicts of interest, both real and perceived.
7. Never use NAES assets or information for personal gain.
8. Recognize that even the appearance of misconduct or impropriety can be very damaging to the reputation of the NAES, and act accordingly.
Conflicts of Interest
These principles provide a framework of integrity for interactions with or on behalf of NAES. However, given the unique makeup of the NAES, more in-depth questions may arise regarding conflicts of interest. For this reason the following guidance is provided:
• NAES defines a conflict of interest as any personal or financial (both direct and indirect) relationship including relationships of family members (see definition below) that could influence or be perceived to influence objectivity when representing or conducting business for, or on behalf of, NAES.
• NAES defines “family” for these purposes as follows: spouse, parent, child or spouse of a child, brother, sister, spouse of a brother or sister, a cohabiting companion, or any other individual with a significant familial or familial-like relationship. Both parent and child shall include step-parent and step-child.
• NAES defines a substantial appearance of a conflict of interest as whenever others may reasonably infer from the circumstances that a conflict exists. Because the appearance of impropriety can be just as damaging as actual impropriety, conduct that appears to be improper must be disclosed so that the appropriate NAES entity may determine whether such substantial appearance of a conflict is deemed to be a prohibited conflict of interest. For these reasons, an individual must recues himself/herself from participating in the NAES case activity giving rise to the substantial appearance of a conflict of interest unless and until it is determined that no conflict exists.
For example, if personal or financial interests exist with any person or concern with whom NAES has a business interest or other relationship or you have a personal or financial relationship with any party to the case, (horse or human) a substantial appearance of a conflict of interest exists and the other relationship or interest could influence or be perceived to influence the objectivity of your decisions relative to the case:
1.
Disclose the interest to the court, where applicable, and all parties.
2. Recusal from any formal or informal discussions related to a relationship between NAES and the person or concern unless authorized by the relevant parties.
Inappropriate hospitality or gift giving between individuals can also create a conflict of interest. Gifts, cash, travel, hotel accommodations, entertainment or favors are neither to be given nor received except those of nominal value exchanged in the normal course of business. Favors or other assets or gifts may be accepted if they are part of open and generally accepted practices and serve to promote the best interest of NAES and would not embarrass the individual or NAES if publicly disclosed and would not compromise objectivity and integrity.
Enforcement
Any person who violates or condones the violation of the Code of Ethics is subject to disciplinary measures, which may include termination of employment in NAES.
This code serves as a framework for ethical conduct but does not cover every situation. If you are unclear about the requirements of this code, please contact the NAES at the following address:
|